Mastercard SPME §9.2 · May 2023 → Sep 2023

General Registration Requirements

substantive

The updated rules introduce financial penalties for Acquirers who fail to register Merchants or Sponsored Merchants as required, including initial fines up to $10,000 and escalating monthly fines for continued non-compliance after a 10-day notice period, emphasizing prompt correction and adherence to Mastercard rules.

Sources Mastercard SPME · May 2023 · page 101 PDF Mastercard SPME · Sep 2023 · page 94 PDF KYB Acquirer current
Also in §9.x this release substantive §9.3 General Monitoring Requirements substantive §9.4.1 Non-face-to-face Adult Content and Services Merchants substantive §9.4.5 Skill Games Merchants substantive §9.4.8 High-Risk Securities Merchants substantive §9.4.9 Cryptocurrency Merchants
Why these edits? The update imposes financial penalties on Acquirers who fail to register Merchants or Sponsored Merchants timely, directly affecting KYB (Know Your Business) obligations for Acquirers under section 2.1.
Mastercard SPME §9.2
This section was substantively restructured between versions (14% text overlap). Compare the texts directly below.
Before · May 2023 · page 101

Security Rules and Procedures—Merchant Edition • 7 February 2023

Customers should send any additional requested information and modification requests by email message to specialty_merchant_registration@mastercard.com. For requirements specific to Merchants that are required to implement the Mastercard Site Data Protection (SDP) Program, refer to section 2.2 of this manual.

After · Sep 2023 · page 94

Security Rules and Procedures—Merchant Edition • 1 August 2023

Mastercard may assess a Customer that acquires Transactions for any of these Merchant or Sponsored Merchant types without first registering the Merchant in accordance with the requirements of the MRP. A violation will result in an assessment of up to USD 10,000. If, after notice by Mastercard of the Acquirer’s failure to register a Merchant or Sponsored Merchant, that Acquirer fails to register its Merchant within 10 days of notice, the Acquirer will be subject to additional assessments of USD 5,000 per month for up to three months, and USD 25,000 per month thereafter, until the Acquirer satisfies the requirement. In addition, the Acquirer must ensure that the violation is corrected promptly. Such Merchant or Sponsored Merchant may also be deemed by Mastercard, in its sole discretion, to be in violation of Rule

Halyard Pay · 2 files
program: Acquirer KYB
- authority: Mastercard SPME 2.1, 11.2.6
+ authority: Mastercard SPME 2.1, 11.2.6, 9.2
required_documents:
- incorporation
- beneficial_ownership
- aml_screen
- license_verification
min_review_cycle_days: 365
suspension_trigger: document_collection_failure
record_retention_years: 7
aml_watchlist_sources:
- ofac_sdn
- eu_consolidated
agent_owner: kyb_agent
# The Acquirer must specifically retain all MATCH records concerning any Merchant, Sponsored Merchant, or ATM owner for at least two years following the termination or expiration of the related agreement, per Mastercard SPME 11.2.6.
# This retention requirement updates prior guidance by imposing a defined minimum retention period beyond the MATCH system's internal data purging schedule.
+ #
+ # Per Mastercard SPME 9.2, Acquirers must register all Merchants and Sponsored Merchants timely to avoid significant financial penalties.
+ # Failure to register after notice may result in assessments starting at USD 10,000 and escalating monthly until correction.
+ # Acquirers must promptly correct any registration violations to comply with these updated requirements.

Acquirer KYB (Know Your Business) Obligations

Acquirers processing transactions on the Mastercard network are required to perform

Know Your Business (KYB) due diligence on merchants before onboarding and on a

recurring basis thereafter. Halyard Pay, as an acquirer, must collect and verify a

minimum set of documents for each merchant to establish business legitimacy, confirm

beneficial ownership, and satisfy anti-money laundering screening requirements.

When this policy applies

This policy applies to all new merchant onboarding and to all periodic re-verification

reviews. Merchants that fail to supply required documentation within the stipulated

period must be suspended from processing until compliance is restored.

Required actions

  1. Collect all required KYB documents at onboarding prior to approval.

  2. Conduct AML screening against applicable watchlists before approval.

  3. Verify business licenses for regulated merchant categories.

  4. Schedule a full re-verification review at least once every 365 days.

  5. Document all verification outcomes and retain records for audit purposes.

  6. Retain all MATCH system records related to Merchants, Sponsored Merchants, or ATM owners for a minimum of two years after termination or expiration of the applicable agreement, to comply with Mastercard's explicit record retention requirements.

7. Ensure all Merchants and Sponsored Merchants are properly registered per Mastercard Registration Program (MRP) requirements before processing transactions. Failure to register timely may result in escalating financial penalties, including initial assessments up to USD 10,000 and subsequent monthly fees up to USD 25,000 until compliance is achieved. Acquirers must promptly correct any registration violations upon notice from Mastercard.

Source authority: Mastercard SPME ��������2.1, 11.2.6.§2.1, §9.2, §11.2.6.

policies/kyb_acquirer/policy.md — after applying change

Acquirer KYB (Know Your Business) Obligations

Acquirers processing transactions on the Mastercard network are required to perform

Know Your Business (KYB) due diligence on merchants before onboarding and on a

recurring basis thereafter. Halyard Pay, as an acquirer, must collect and verify a

minimum set of documents for each merchant to establish business legitimacy, confirm

beneficial ownership, and satisfy anti-money laundering screening requirements.

When this policy applies

This policy applies to all new merchant onboarding and to all periodic re-verification

reviews. Merchants that fail to supply required documentation within the stipulated

period must be suspended from processing until compliance is restored.

Required actions

  1. Collect all required KYB documents at onboarding prior to approval.

  2. Conduct AML screening against applicable watchlists before approval.

  3. Verify business licenses for regulated merchant categories.

  4. Schedule a full re-verification review at least once every 365 days.

  5. Document all verification outcomes and retain records for audit purposes.

  6. Retain all MATCH system records related to Merchants, Sponsored Merchants, or ATM owners for a minimum of two years after termination or expiration of the applicable agreement, to comply with Mastercard's explicit record retention requirements.

7. Ensure all Merchants and Sponsored Merchants are properly registered per Mastercard Registration Program (MRP) requirements before processing transactions. Failure to register timely may result in escalating financial penalties, including initial assessments up to USD 10,000 and subsequent monthly fees up to USD 25,000 until compliance is achieved. Acquirers must promptly correct any registration violations upon notice from Mastercard.

Source authority: Mastercard SPME ��������2.1, 11.2.6.§2.1, §9.2, §11.2.6.

Source authority: Mastercard SPME §9.2.

--- a/policies/kyb_acquirer/rules.yaml
+++ b/policies/kyb_acquirer/rules.yaml
@@ -1,5 +1,5 @@
 program: Acquirer KYB
-authority: Mastercard SPME 2.1, 11.2.6
+authority: Mastercard SPME 2.1, 11.2.6, 9.2
 required_documents:
   - incorporation
   - beneficial_ownership
@@ -13,4 +13,8 @@
   - eu_consolidated
 agent_owner: kyb_agent
 # The Acquirer must specifically retain all MATCH records concerning any Merchant, Sponsored Merchant, or ATM owner for at least two years following the termination or expiration of the related agreement, per Mastercard SPME 11.2.6.
-# This retention requirement updates prior guidance by imposing a defined minimum retention period beyond the MATCH system's internal data purging schedule.+# This retention requirement updates prior guidance by imposing a defined minimum retention period beyond the MATCH system's internal data purging schedule.
+#
+# Per Mastercard SPME 9.2, Acquirers must register all Merchants and Sponsored Merchants timely to avoid significant financial penalties.
+# Failure to register after notice may result in assessments starting at USD 10,000 and escalating monthly until correction.
+# Acquirers must promptly correct any registration violations to comply with these updated requirements.

--- a/policies/kyb_acquirer/policy.md
+++ b/policies/kyb_acquirer/policy.md
@@ -20,5 +20,6 @@
 4. Schedule a full re-verification review at least once every 365 days.
 5. Document all verification outcomes and retain records for audit purposes.
 6. Retain all MATCH system records related to Merchants, Sponsored Merchants, or ATM owners for a minimum of two years after termination or expiration of the applicable agreement, to comply with Mastercard's explicit record retention requirements.
+7. Ensure all Merchants and Sponsored Merchants are properly registered per Mastercard Registration Program (MRP) requirements before processing transactions. Failure to register timely may result in escalating financial penalties, including initial assessments up to USD 10,000 and subsequent monthly fees up to USD 25,000 until compliance is achieved. Acquirers must promptly correct any registration violations upon notice from Mastercard.
 
-Source authority: Mastercard SPME 2.1, 11.2.6.+Source authority: Mastercard SPME §2.1, §9.2, §11.2.6.